When we ask you for specific details, we’ll always:
• be clear about why we need them
• make sure that your personal information is kept secure
• Zinc eConsulting Ltd (‘we’ and ‘us’) means Zinc eConsulting Ltd and Zinc eConsulting Ltd
• We’re committed to protecting your privacy. We comply fully with the 6 principles of the GDPR (General Data Protection Regulation), and aim to maintain best-practice standards in our processing of personal and/or sensitive personal data.
The GDPR Principles are:
Principle 1: Personal data shall be processed lawfully, fairly and in a transparent manner
Principle 2: Personal data should be collected for specific, explicit and legitimate reasons
Principle 3: Personal data processing should be adequate, relevant and limited to only what is necessary
Principle 4: Personal data should be accurate and where necessary up to date
Principle 5: Personal Data should only be retained as long as necessary
Principle 6: Personal data should be processed in an appropriate manner to maintain security
Data Subject – You, any customer of Zinc eConsulting Ltd
Data Controllers – Zinc eConsulting Ltd
Data Processors – Zinc eConsulting Ltd, Any freelance DVSA registered driving instructor who is registered to provide work for Zinc eConsulting Ltd if you are located in the UK and are having on-road driver training delivered by us.
• We may provide more specific information about how we use personal and/or sensitive personal data in our product or service specific documentation, such as any policy documentation or literature.
How do we use your information?
As a Data Subject you can ask for extensive information on the data we hold about you, concerning:
The purpose of the processing
The categories of personal data concerned
The recipients to whom the personal data have been or will be disclosed
The period for which the personal data will be stored
The right to rectification, erasure, restriction or objection
The right to lodge a complaint with a Supervisory Authority
Where the personal data is not collected from the Data Subject, any available information as to their source
We use the information we receive from you, together with information we’ve obtained in the course of our relationship with you (including in relation to goods and/or services we provide to you, and/or your use of those goods and/or services), to:
• provide goods and/or services that you request
• communicate with you
• personalise information sent to you
You have a right to complain to the ICO if you think there is a problem with the way we are handling your data.
How and where we use your data in Zinc eConsulting Ltd:
If you are using our Dora online risk assessment:
• If you are using DORA our online risk assessment tool, we will hold your data for as long as your Dora account or the master Dora account, where you took the assessment, is registered with us. If the account is active we will then deem it still relevant that you wish to access the data, which will include your name and driving details such as year experience, responses to questions etc.
If you are UK based and having on-road driver training with us:
• We store your details, such as name, address, phone number, driving notes, on our CRM system to help manage course bookings or to store as an ongoing lead for a period of up to 12 months.
• After 12 months from initial enquiry that you would have made to us on email or phone, we will delete your data if you, 1. Have not placed a booking in that period, or 2. Have placed a booking but not booked an additional course.
• We allow 12 months, as some customers do make repeat bookings months apart. So by having your contact details on our system for 12 months will allow us to quickly access your info, and provide a convenient, personalised service for you.
• If a driving course booking takes place, we will pass your details to our registered driving tutors, so they know your address, phone number etc to enable the arrangement of a driving course.
• Your post-course driving report will be held on our servers for a period of 5 years. Often we are asked for repeat course reports, and so securely storing all reports, which will hold a drivers name, car registration, date of training and driving notes, will help customers both past and present, should they need a copy of their driving report.
What we will NOT do with your data:
• We will not send you any newsletters or any such marketing material, unless you have given your explicit consent beforehand.
• We will not sell your details or share your details with any non-driving course related third party individuals or businesses.
Examples of how we may personalise information include:
• sending you updates on course bookings you have made
• sharing your details with our driving instructors who are providing the driver training for you
We don’t sell your personal information to third parties for marketing purposes.
We store the information you provide to us, including:
• information provided via forms you complete on our website
• information which we may collect from your browsing
Our servers, in common with nearly all web servers, log each page that’s downloaded from the site.
Any new information you provide to us may be used to update an existing record we hold for you.
If you give us a work email address, we won’t be responsible for third parties (who are authorised to access your work email address) having access to any communications we send.
We do not store credit card details nor do we share customer details with any 3rd parties
When do we give third parties your data?
• We will not share your details with any third parties accept to driving instructors who are providing driver training for you or someone you have arranged the driving course for.
Why do we ask for your home, mobile phone number, and email address?
• so we can contact you about an enquiry you’ve made
• to contact you about relevant products or services
• to contact you if there’s a problem with your order
• for any other reasonable reason to do so
Why might we need to call you?
We make outbound phone calls for a number of reasons including to confirm a course booking, or to follow up on a course enquiry.
Zinc eConsulting Ltd Data Protection Officer, Suite 3 High Street Chambers, 10-11 High Street, Shrewsbury, Shropshire, SY1 1SP
If you have more than one address or email address registered with us, please make sure to:
• tell us which of these you’d prefer we contacted you on
• update your preferences if they change
What we may use your information (and contact details) for:
• To confirm any course bookings and enquiries
• To allow our tutors to contact you regarding a booking
• To send you post course driving reports
• Recording your name, car registration, and driver training notes, on post course driving reports
If we give information to a third party (either a provider of a product or service, or an external data processing agency such as a mailing house) we’ll exercise strict control over it contractually, typically requiring it – and any of its agents and/or suppliers – to:
• maintain the security and confidentiality of the information, and restrict access to those of its own employees
• only use the data for the purpose agreed with us, and prevent it being used for any other purpose by any other party
• refrain from communicating with you, except if it’s about the product or service in question
• return the data to us at the end of any contract term
• destroy or delete any copies made of all or any part of the information, unless copies need to be kept to comply with applicable law or regulations
We will also restrict the information disclosed to the absolute minimum necessary, e.g. to provide the product or service.
Your data, your consent
When you provide us with any data we‘ll always try, where possible, to:
• make it clear why we need it
• and (where required by law) obtain your consent to our use of it
How do we use other people’s data?
Where we deem appropriate, we may allow you to give
consent on behalf of your spouse/partner/other relevant person.
If you provide consent on behalf of another person, you must ensure that you have their authorisation to do so. We reserve the right to request confirmation or to otherwise verify that you have that authorisation.
What are cookies?
In short: cookies are small data files that a website will put on your device. We’re keen to find out what you like and dislike; your feedback plays a key role in helping us improve this site.
We use many techniques to follow your use of the site and provide you with a customised experience. The main and best known technique is by using what are known as ‘cookies’. The data contained in the cookie can be retrieved by that website (or another website that can read the cookie) when you visit the relevant site.
Cookies cannot affect your device, but they do collect information that can be used to enhance the site. For example, a cookie can remember the items that you’ve placed into your shopping basket, or it can ensure you get the offer you requested. Typically, these will be ‘session’ cookies, which expire as soon as you leave the site.
Other cookies can tell us if you come back. These are ‘persistent cookies’, which expire after a period of time unless you delete them from your device. We use them to help customise the site and to do things such as display relevant advertising on the websites you visit based on your visit to our website.
Some cookies enable sites to work, while others help us learn about what people are browsing for.
The main types of cookies we use on our site and what they do:
1. Strictly necessary cookies
These cookies enable you to get the information or service you’ve asked for. They’re essential – without them, some services may not work. To give you an example: we use these cookies to enable you to use shopping baskets, which remember your choices as you navigate our site and enable you to buy.
2. Performance cookies
These cookies collect information about the pages you visit, where you go most often, and whether you see error messages. The information is only used to ensure our website works well. For instance, we gather information to diagnose problems and issues. We then use this to make improvements and fix errors.
3. Functional cookies
These cookies remember choices you’ve made to personalise the site. They may remember where you are so you can get tailored information, or remember changes you’ve made to help you browse, such as increasing the text size. For instance, if you ask for services based on your location, we sometimes store a cookie – meaning that next time you visit, you won’t have to tell us your location again.
4. Targeting or advertising cookies
These cookies collect information about your browsing habits (including details of the websites you’ve visited) which is then used to ensure you receive advertising relevant to you.
For instance, these cookies may be used by us (or third parties and advertising networks on our behalf) to serve ads relevant to you across the internet (including on other sites you visit), based on your interaction with our website and your browsing history.
What about links to other sites – and what about their cookies?
We often link to other sites to help provide you with extra information or services; links to Twitter, Facebook and other popular social media or book-marking sites make it easy for you to share information with your family and friends.
How to control cookies
You can restrict, remove or block cookies through your browser settings at any time. For more information about how to do this, and about cookies in general, visit All About Cookies.org and Your Online Choices.eu.
Certain cookies may be set as soon as you visit our website, but you can remove them using your browser settings. If cookies are disabled on your device you’ll still be able to use most of this site, but it may limit what you can do.
Why would we need to disclose your information to third parties?
As we’ve mentioned, we don’t sell your personal information to third parties for marketing purposes.
‘How we use your information’ outlines how we may exchange personal data with third parties to:
• help us prevent fraud and money laundering
• assist us in providing a quote
• check which payment options we can make available to you
• (where appropriate) ensure that we only send you information about products and services that are likely to be of interest to you
Cross-border transfers of information
The laws of some non-EEA countries do not provide the same level of protection for personal data as the laws of the UK.
Where we transfer your personal data to such countries, we’ll take steps to ensure appropriate protections are in place to safeguard your personal data, as required by the General Data Protection Regulation (GDPR).
Each time you receive electronic marketing information or a message, you can opt out from receiving any more marketing information from us.
Want to opt out by post?
If you don’t want to receive marketing information from us, write to: Zinc eConsulting Ltd, Suite 3 High Street Chambers, 10-11 High Street, Shrewsbury, Shropshire, SY1 1SP
How do we amend and retain your information?
It’s useful for us – and for you – if we have your most up-to-date information, so please tell us in writing about any changes in your circumstances, and we’ll amend your details. By law and regulation, we’re obliged and allowed to keep certain types of data for a minimum period of time. This tends to be for six years, but can be longer if the statute or regulation requires or permits
Subject access requests: how to get a copy of the data we hold about you
You have a statutory right of access to personal and/or sensitive personal data that we hold about you. You can request to have all your data we hold about you deleted in full. We will delete this data, within 72 hours of receiving a letter from you, and inform you by phone call or post within 2 hours after this has been actioned.
To exercise this right, please write to: Data Protection Officer, Zinc eConsulting Ltd, Suite 3 High Street Chambers, 10-11 High Street, Shrewsbury, Shropshire, SY1 1SP
Please refer to the information you wish to see giving dates if possible. We will not administer Subject Access Requests made by a third party, unless it arrives with the written authority of the person who’s the subject of the request.
How do you choose the type of information you receive?
You have the option at any time to:
• change the type of material sent to you at any time
• choose which products and services you wish to receive information about
• cancel any previous expressions of interest in particular areas
To do this, write to: Data Protection Officer, Zinc eConsulting Ltd, Suite 3 High Street Chambers, 10-11 High Street, Shrewsbury, Shropshire, SY1 1SP.
• update all relevant documentation, and
• post any changes on our websites
so that you’re always aware of what information we collect, how we use it, and under what circumstances we disclose it.
Provide us with feedback:
We welcome your questions and comments about privacy. If you have any, please write to: Data Protection Officer, Zinc eConsulting Ltd, Suite 3 High Street Chambers, 10-11 High Street, Shrewsbury, Shropshire, SY1 1SP